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 June 26, 2025

David Boral
Chief Executive Officer
D. Boral ARC Acquisition I Corp.
10 E. 53rd Street, Suite 3001
New York, NY 10022

 Re: D. Boral ARC Acquisition I Corp.
 Amendment No. 1 to Registration Statement on Form S-1
 Filed June 11, 2025
 File No. 333-286810
Dear David Boral:

 We have reviewed your amended registration statement and have the
following
comments.

 Please respond to this letter by amending your registration statement
and providing
the requested information. If you do not believe a comment applies to your
facts and
circumstances or do not believe an amendment is appropriate, please tell us why
in your
response.

 After reviewing any amendment to your registration statement and the
information
you provide in response to this letter, we may have additional comments. Unless
we note
otherwise, any references to prior comments are to comments in our May 23, 2025
letter.

Amendment No.1 to Registration Statement on Form S-1
Cover page

1. In the paragraph starting with As more fully discussed in
Management Conflicts
 of Interest , please revise to briefly address the reimbursement
of any out-of-
 pocket expenses related to identifying, investigating and completing an
initial
 business combination.
Sponsor Information , page 13

2. We note your response to prior comment 5. We note that your CEO is also
the CEO
 of D. Boral Capital, the sole book-running manager and representative of
the
 underwriters, beneficially owns interests that contain solely of the
representative
 shares and David Boral is a deemed to be a promoter of the company as
disclosed on
 June 26, 2025
Page 2

 page 156. Please revise the compensation tables on pages 13 and 112 to
disclose the
 compensation of representative shares in connection with this offering
or advise us in
 more detail why the representative shares should not be disclosed in the
compensation
 tables. See Item 1602(b)(6) of Regulation S-K.
Exhibits

3. We note your auditor's consent at exhibit 23.1. Please have your auditor
revise their
 consent to remove the reference to "post-effective" when referring to
this amendment.
 Further, please have your auditor revise their consent to include the
correct name of
 the registrant.
 Please contact Peter McPhun at 202-551-3581 or Jennifer Monick at
202-551-3295 if
you have questions regarding comments on the financial statements and related
matters. Please contact Pearlyne Paulemon at 202-551-8714 or David Link at
202-551-3356
with any other questions.

 Sincerely,

 Division of
Corporation Finance
 Office of Real
Estate & Construction
cc: David Levine
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